This week Customs released something that has been long-anticipated by the JM Rodgers and the drawback community: a General Manufacturing ruling.
Prior to the implementation of TFTEA last February, there was a long-standing general ruling called TD 81-300 that was widely used to simplify the ruling process. Unfortunately, due to the new substitution rules in TFTEA, it was invalidated. Since then, not having the general ruling has been a major point of contention between trade and Customs, and a new draft has been subject to some delay.
Last week Customs released a new version of a General Ruling, now updated with TFTEA regulations. With substitution matching now on HTS codes, this general ruling has been finally updated to reflect the new regulations.
A general ruling is broader, and for certain kinds of manufacturing we will not have to provide the same detailed lists of things like all HTS codes in a column, and it should be accepted as if it were there. In the past, these were easier to put together and processed much quicker, and Customs seeks to make this the case going forward.
With more and more manufacturers seeking to take advantage of duty drawback, this will be a boom to anyone seeking to claim manufacturing drawback. By eliminating some of the more onerous necessities in a ruling for certain manufacturers, Customs is seeking to both reduce their paperwork burden and process rulings through to approval more quickly. This is good news for many manufacturers, as it will allow a shorter time period between beginning their drawback program and getting a refund from Customs.
If you’d like to discuss how manufacturing drawback can work for your company, please contact www.jmrodgers.com
James Rodgers CEO